Waste classification guidelines for NSW waste generators
Follow NSW waste classification guidelines in order, check PFAS requirements and confirm the receiving facility can accept your waste before delivery.
In NSW, waste classification guidelines are the EPA's six-step process, read with Waste Classification Guidelines Part 1 and any applicable addenda, including the PFAS addendum. These classes are NSW rules, not an Australia-wide system. You also have to confirm the receiving facility can take the class, as the NSW EPA guidance explains.
The EPA classification page still links the 2014 Part 1 guidelines. Read the addenda with that PDF. For waste that contains or may contain PFAS, the 2014 document is not enough on its own.
The six NSW waste classes
The NSW EPA lists six types of waste:
- Special waste
- Liquid waste
- Hazardous waste
- Restricted solid waste
- General solid waste (putrescible)
- General solid waste (non-putrescible)
The generator is responsible for choosing the correct class under the NSW framework. Inert waste is not a seventh class on that list, and a dry or inert look is no basis for assuming the material is uncontaminated. Dangerous waste is not on the list either. Run the six steps instead of treating that phrase as a class name.
What does putrescible waste mean?
For general solid waste, step 6 of the EPA process asks whether the waste is capable of significant biological transformation. It's not a wet-versus-dry test. Don't assign the non-putrescible class just because a load looks dry.
How to use the NSW EPA waste classification guidelines
Apply the steps in order. They are decision stages, not six laboratory tests that every waste must undergo. The EPA's ordered process is:
| Step | Question or action |
|---|---|
| 1 | Is it special waste? |
| 2 | If it is not special waste, is it liquid waste? |
| 3 | Is it pre-classified? |
| 4 | Does it have hazardous characteristics? |
| 5 | If it remains unclassified, undertake chemical assessment. |
| 6 | If chemical assessment establishes general solid waste, assess whether it is putrescible or non-putrescible. |
Stop once a step establishes the class. Don't go to the next step. The only exception is special waste mixed with restricted solid or hazardous waste. Otherwise, mixed waste must be classified according to the highest class of waste. The classification guidelines give the example of a non-liquid waste with three contaminants, other than asbestos, tyres, or clinical and related waste. If only one of those contaminants is at the hazardous concentration, classify the waste as hazardous waste.
The EPA guidelines also set two defaults where an assessment is missing. Waste left unclassified after steps 1 to 4 must be classified as hazardous waste if step 5 chemical assessment is not undertaken. If step 5 establishes general solid waste but you do not assess whether it can undergo significant biological transformation, the guidelines require you to classify it as general solid waste (putrescible).
Special waste can need two classifications
Where special waste is mixed with restricted solid or hazardous waste, classify it and manage it as both. The EPA's mixture guidance names asbestos, tyres, and clinical and related waste. Identifying asbestos in that mix does not remove the restricted solid or hazardous classification. Follow the special-waste mixture guidance.
Chemical assessment, PFAS and dilution
Chemical assessment separates contaminant concentration from leachability. The EPA's classification-report guidance refers to specific contaminant concentration (SCC), contaminant threshold (CT) and toxicity characteristics leaching procedure (TCLP) threshold values. Use the official guidelines for the relevant test route and limits. A concentration result is not a leachability result.
Waste that contains, or may potentially contain, PFAS must undergo chemical assessment consistent with step 5. Cover PFOS, PFHxS and PFOA in accordance with the addendum. The EPA page that links the addendum says the addendum contains the interim SCC and TCLP test values. Use that addendum for the values. Do not take them from the 2014 Part 1 PDF alone.
Dilution is not an acceptable waste-management option. The EPA guidelines say two or more classes of waste must not be mixed to reduce contaminant concentrations, and water must not be added before classification analysis. There must also be a scientifically valid reason to exclude sample results.
Before sending waste off site
An EPA licence does not mean a facility can accept every waste class. Check the POEO public register to see whether the facility is licensed by the EPA, then read its environment protection licence for permission to receive your waste. If the facility is not licensed by the EPA, the EPA recommends you check that it has local council consent to receive that class and undertake its waste activities. The EPA's generator guidance sets out these checks. Classification on its own does not prove the facility can take the waste.
Waste classification does not assess suitability for application to land or use as fuel. Resource recovery orders and exemptions need their own check, as the EPA guidance explains. A general solid waste class is not permission for beneficial reuse.
Do these waste classes apply across Australia?
No. NSW labels should not be carried into another state's assessment without checking that jurisdiction's framework. Victoria, for example, uses industrial waste, priority waste and reportable priority waste. Priority waste is a subset of industrial waste. Reportable priority waste is a subset of priority waste. Its regulator points to waste codes and pre-classifications in Schedule 5 of the Environment Protection Regulations 2021. See EPA Victoria's industrial waste classification guidance.
RegAffairs AI's answer on classifying waste in NSW is a starting point, not a certified waste classification.